A key driver must be to ensure legal certainty

We welcome the general direction of the European Commission Proposal for a Regulation on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilisation in the Union COM (2012) 576 final, but have a number of concerns regarding some of its ambiguous language and, by association, its lack of legal certainty.

Speaking for their member companies the German Chemical Industry Association (Verband der Chemischen Industrie e.V.) and the German Biotechnology Industry Association (DIB) support the objectives of the Convention on Biological Diversity (CBD): The conservation and sustainable use of biological diversity as well as the fair and equitable sharing of benefits arising from utilization of genetic resources.

The chemical and biotechnology industry, hereinafter referred to as industry or the industry, fully supports the CBD underpinning the Protocol and stands ready to work with the German government and the EU on ensuring the Protocol’s fair and balanced implementation in Germany and across the EU.

A key driver in that process must be to ensure legal certainty for potential users of genetic resources in the EU.

We welcome the general direction of the draft Regulation but have a number of concerns regarding some of its ambiguous language and, by association, its lack of legal certainty.